Case 1:18-cr-00204-NGG-VMS Document 430 Filed 03/13/19 Page 21 of 30 PageID #: 4309
which offense was effected by force, fraud, coercion and a combination of such means, contrary to Title 18, United States Code, Sections 1591(a)(l) and 1591(a)(2).
(Title 18, United States Code, Sections 1594(c), 159l(b){l) and 3551 et seq.)
COUNT NINE (Sex Trafficking - Jane Doe 5)
47. In or about and between February 2016 and June 2017, both dates being approximate and inclusive, within the Eastern District of New York and elsewhere, the defendants KEITH RANIERE, also known as "Vanguard," "Grandmaster" and "Master," and ALLISON MACK, together with others, did knowingly and intentionally recruit, entice, harbor, transport, provide, obtain, maintain, patronize and solicit a person, to wit: Jane Doe 5, in and affecting interstate and foreign commerce, and did benefit, financially and by receiving anything of value, from participation in a venture that engaged in such acts, knowing and in reckless disregard of the fact that means of force, threats of force, fraud and coercion, and a combination of such means, would be used to cause Jane Doe 5 to engage in one or more commercial sex acts, which offense was effected by force, fraud, coercion and a combination of such means.
{Title 18, United States Code, Sections 159l(a)(l), 159l{a)(2), 1591(b)(l), 2 and 3551 et seq.)
COUNT TEN (Attempted Sex Trafficking-Jane Doe 8)
48. In or about and between February 2016 and June 2017, both dates being approximate and inclusive, within the Eastern District of New York and elsewhere, the defendants KEITH RANIERE, also known as "Vanguard," "Grandmaster" and "Master," and ALLISON MACK, together with others, did knowingly and intentionally attempt to
